Chalmers v. Cayne

Summary

The United States District Court for the Northern District of California grants Defendant Brian Cayne’s motion for judgment on the pleadings in Caitlin Chalmers’s action arising from the dissolution of their romantic relationship. The court holds that California Civil Code sections 43.4 and 43.5 bar several contract and misrepresentation claims, while the remaining claims are inadequately pleaded or seek a remedy rather than an independent cause of action. The court grants leave to amend most claims but dismisses the constructive-trust claim without leave to amend, setting October 24, 2025, as the amendment deadline.

Holdings

1. Judgment on the pleadings was proper because, accepting the complaint's well-pleaded facts as true, the pleadings showed that plaintiff could not state viable claims and defendant was entitled to judgment as a matter of law.
2. Sections 43.4 and 43.5 barred plaintiff's claims for breach of oral contract, breach of implied contract, promissory estoppel, fraud, and negligent misrepresentation because the alleged promises concerned marriage, cohabitation, financial support, and shared property traditionally associated with marriage.
3. Plaintiff did not plausibly allege an enforceable Marvin agreement because the alleged agreement was connected to a promise of marriage and the relationship was not sufficiently stable or significant based on its duration, limited cohabitation, and lack of allegations that the parties held themselves out as married, jointly owned property, or pooled assets.
4. Plaintiff did not plausibly allege a partnership or a claim for dissolution of partnership assets because she did not allege a right of joint participation in management and control of the alleged assets or business.
5. Plaintiff did not plausibly allege a fiduciary duty because the parties were unmarried, no partnership was adequately alleged, and the complaint did not allege that Chalmers entrusted property to Cayne or that Cayne exercised control over her property.
6. Plaintiff failed to state a claim for intentional infliction of emotional distress because she did not plead facts supporting severe emotional distress or the requisite intent or reckless disregard, although the court would not decide as a matter of law whether the alleged conduct was extreme and outrageous.
7. Plaintiff failed to state a conversion claim because her allegations that Cayne received, kept, and concealed her belongings were conclusory and internally inconsistent.
8. A constructive trust is an equitable remedy, not an independent cause of action, so plaintiff's constructive-trust claim was dismissed without leave to amend.

Questions Presented

1. Whether judgment on the pleadings was proper under Federal Rule of Civil Procedure 12(c).
2. Whether California Civil Code sections 43.4 and 43.5 barred plaintiff's contract, implied-contract, fraud, promissory-estoppel, and negligent-misrepresentation claims arising from alleged promises of marriage, cohabitation, financial support, and shared property.
3. Whether plaintiff plausibly alleged an enforceable Marvin agreement based on a stable and significant cohabiting relationship independent of a promise to marry.
4. Whether plaintiff plausibly alleged a partnership by pleading a right of joint management and control.
5. Whether plaintiff plausibly alleged a fiduciary duty, intentional infliction of emotional distress, or conversion.
6. Whether a constructive trust could be maintained as a standalone cause of action and whether leave to amend should be granted.

Disposition

other